PRIVACY RIGHTS, USES
AND
SECURITY POLICIES (Last Update:  January 1, 2021)

Your privacy and the protection of your sensitive personal information are important to us. Because we collect and/or store certain types of information from and about you, it is necessary to explain our policy and the terms and conditions surrounding the capture and use of that information.

Employee Conduct

Semble expresses its absolute commitment to integrity, and our corporate values and ethical standards and the associated business conduct we expect from all of our employees. This includes very specific guidelines concerning the safeguarding of confidential information, which includes customer information. In general, these guidelines limit employee access to confidential information, and limit the use and disclosure of such information to specifically authorized processes and transactions. If it is determined that employees have violated these guidelines, corrective action may be taken, including immediate dismissal.

Verification of Practices

Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information. These reviews may be conducted by our own internal staff, external accounting and auditing firms, and possibly government regulators. Included in these self-assessments and examinations are reviews of the controls and safeguards related to consumer privacy.

Introduction

This policy discloses which information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any personal and/or personally identifiable information that we may request will be used; these explanations can usually be found on the same pages where the information is requested. We also detail below our security policy which describes how your personal information is protected both electronically and physically.

In general, and as described in detail below, we collect several types of information from you:

• Information required to verify your identity
• Information necessary in establishing a borrower request or investing in issuer notes.
• Optional information you may wish to share in the furtherance of your goals in using our Platform
• Information about your visits to and use of this web Platform or the web sites of third party servicers to help us maintain the appropriate features, functionality and user experience

Information We Collect From You and About You

Our collection of information while you use the Platform predominately occurs during registration and subsequent loan application. Some information is required and some is optional, some will remain private and some will be displayed to other users. We always let you know which is which. Additional information may be gathered during your subsequent use of the Platform, whenever you choose to provide it.

Certain personal information must be supplied during the registration process, as indicated below, in order to (a) enable registered users to login to the Platform, (b) provide details around the creditworthiness of the borrowers, (c) verify the identities of users, (d) establish that users are at least 18 years of age, and (e) guard against potential fraud. This basic personal information includes:

• Name (borrower/member registration)
• Email address (borrower/member registration)
• Mailing address and telephone number (borrower/member registration)
• Your Social Security Number or EIN (borrower/member registration)

When you register as a borrower, we will use this information to pull a credit report from a credit bureau to determine your creditworthiness as well as to help members assess your loan request in the context of your overall financial situation. We will also use your required and optional information to facilitate activities and transactions that need to occur during the process, such as:

• Generating public profiles around the borrower loan requests on the Platform
• Enabling financial services partners to implement automatic payments and fund transfers
• Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
• Implementing collection activities as needed
• Maintaining regular communications with you concerning transactions you initiate, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, etc.

When you register as a member, we will request some required and optional data in order to facilitate such activities as:

• Generating a public member profile on the Platform
• Enabling our financial services partners to verify identity, implement fund transfers and the receipt of borrower payments
• Enabling our financial services partners to implement automatic payments and fund transfers
• Contacting you if there is a problem completing a transaction you requested or to discuss a problem with your account
• Maintaining regular communications with you as may be necessary to execute transactions you request, such as transferring funds, etc.

In addition, we gather names and email addresses of people who contact us through our web Platform with questions about our company. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people, such as in the case of job applicants who submit resumes, etc.

Finally, we (and/or our service providers) collect information about your computer and your visits to our web Platform, such as your IP address, geographical location, browser type, referral source, length of visit, and page views through the use of log files. We (and/or our service providers) use this aggregated information in the administration of our web Platform to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities. We (and/or our service providers) use non-identifying and aggregated information to help optimize our web Platform based on the needs of our users.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Tell-a-Friend and Other User Referral Activities

Users may choose to refer friends to the Platform or directly to their loan listings via email. If this referral occurs independently of our Platform or a partner’s site, we do not track the referral other than as a unique page view. Since we do not collect any information from the referring party or the recipient of the external email referencing our Platform, we do not capture or store any information about either party. If friends refer each other to our Platform or to their loan listings via a partner’s site, we will store and track information about the referring and receiving parties only long enough to determine the effectiveness of our marketing activities which contributed to the referral.

Our users can also refer friends to the Platform by completing a simple form to generate an email invitation. In this case, the email invitations do not track back to any particular loan request, and the sender will not know whether you are a borrower, investor or simply a member. The information collected in this process is only kept long enough to monitor whether the referral program is achieving the desired results in terms of attracting new visitors to the Platform and converting them into members. Again, these are messages initiated by friends of the recipients, and the recipients will not be added to any mailing list or contacted by us apart from this referral process, which may include invitation reminders. In the case where a bonus is offered to a member in return for the referral, we will only retain the information about the referred parties to properly credit the account of the member initiating the referral. The information is not used for any other purpose.

Communications from Our Platform

When you register on our Platform you will receive emails that confirm specific actions you requested. You will receive notifications confirming your registration, the successful verification of email addresses and bank accounts, and confirmation of successful submissions of loan requests. You will also receive progress updates on the status of loan requests and submitted portfolios. These are transactional notifications that you cannot opt out of receiving, as they are in place to protect the security of your account and your personal information. We may also send you responses to emails you send us, if appropriate or applicable. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Platform operations or marketing offers from us or from us on behalf of our marketing partners. The completion of these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.

Links to Third Party Websites

We are not responsible for the information practices employed by sites linked to or from our website. In most cases, links to non-Semble websites are provided solely as an access point to obtain information on products and topics that may be useful to the users of our Platform. Third party websites may have different privacy policies and/or security standards governing their sites.

How and When Your Information Is Shared With Other Parties

Information is shared with other parties in the following ways:

• Required and optional information about borrowers and investors is displayed on public profiles that members can update at any time; certain information is optional and you can choose not to supply it and/or can remove the optional information at any time. We may, but is not obligated to, monitor any entered optional information to assist in the protection of your identity.
• Personal but not sensitive information about borrowers is contained in loan listings that can be viewed by all users.
• Financial and credit information about borrowers is displayed on listing pages and as such is made publicly available, and is contained anonymously in loan data files available on the statistics page.
• Information is shared directly between users and other or potential users. Information shared directly by users might contain personal information.
• We may, with your consent, share required and optional information about you.

For privacy purposes, members investing remain anonymous on the Platform unless they consent otherwise. Borrowers have public profiles and related listings on the Platform that display their information to any users who views these pages. The listing pages include borrowers’ credit report and other financial information that is shown to potential investors so that they can effectively evaluate loan requests. As noted above, this information is also contained anonymously in loan data files available on the statistics page. Loan listings also contain certain personal information and, in some cases, answers to questions posed by investors, and loan descriptions that are incorporated into listings.  Finally, members creating blog/forum posts are identified by their screen names.

To protect privacy, however, the blog/forum posts do not track back to listings or note purchasing decisions. We are not responsible for any personal information that users may choose to reveal about themselves through the Platform. Given the community nature of any transaction site, however, it may be in the best interests of borrowers to share some level of personal information in order to achieve a satisfactory outcome (i.e., it may be necessary for you to share a certain amount of personal information in order for a loan to receive full funding).

If you use our blog on this Platform, you should be aware that any personal information you submit there can be read, collected, or used by other users of this forum, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in this forum. To request removal of your personal information from our blog, contact us at support@semble.techhubwithashutosh.com.

We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personal information when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Platform.

We works with a number of trusted partners that perform vital functions as part of our operations, including credit bureaus, electronic payment service providers, and customer support call centers. Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services. Our partners are legally required to keep your information private and secure.

Testimonials

We display personal testimonials of satisfied customers on our Platform in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@semble.techhubwithashutosh.com.

How Your Credit History and Loan Data Are Shared

When a listing is created, you will be posting personal information on the Platform that will be visible to all users. This information includes details about your loan request, as well as your organization’s name, geographic location, description of the loan request, credit information, financial documentation, and other relevant documentation in relation to the loan request.

It is necessary to allow prospective investors to see this information as they evaluate your loan request. The information displayed to investors includes a credit report which has a credit history section. As noted above, this information is also contained anonymously in loan data files available on the statistics page.

If you successfully receive a loan, we will also display status information about your loan to the members who invested in the notes corresponding to your loan. Your payment performance information such as late payments, collections activity or any other instances of delinquency will be displayed to these investors as well. Loan status information is also aggregated and displayed on the statistics page.

Notifications

We will send you email notifications from time to time, and these are required elements of your transactions on our Platform, such as confirmations of particular actions you have taken. These required notices are sent typically to notify you of a change in status or for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that no one can make a change to your account without your knowledge, such as confirming the addition of a new email address or linked external bank account. These notifications are sent to you so that you can be assured that no one is making changes to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Platform policies. Generally you may not opt out of these service related emails.

Where You Can Find and/or Correct Your Information

You can access all of your personal information that we collect online and maintain by visiting your profile in the Log In section of our Platform. This section of the Platform is password-protected to better safeguard your information. As a registered user, you can update your password, email address, physical address, phone number and bank account information at any time on the Platform, and if you need to change any other information in your profile you can contact us at support@semble.techhubwithashutosh.com. To protect your privacy and security, please contact us at support@semble.techhubwithashutosh.com to make changes to your sensitive account information.

Web-related Information Collection

We use web beacons or pixel tags, which are tiny graphics, in conjunction with cookies on our Platform, including session ID cookies, non-persistent cookies and persistent cookies. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser and load the pages according to a user’s preferences for that particular site, including the personalization of content. Cookies are also used to gather statistical data, such as which pages are visited, what is downloaded, the ISP’s domain name and country of origin, and the addresses of sites visited before and after coming to our Platform, as well as your “click stream” activity (meaning, the paths taken by visitors to our Platform as they navigate from page to page) and transactional attributes in accordance with information you voluntarily submit in the course of using our Platform. This data is aggregated for analysis to ensure proper functioning of our Platform, in terms of navigation and usability, as well as to evaluate the effectiveness of our marketing efforts. At no time do any of our cookies capture any personal information. More importantly, using cookies also helps us protect the security of your account. Session ID cookies follow your activities on our Platform so that we can ensure that no one is making changes to your profile, applying for loans or making loans on your behalf. This information is encrypted and no personal data about you is stored on our servers.

We may send a cookie that can be stored by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of our Platform, to improve its usability and for evaluating our marketing effectiveness as described above. We may also use that information to recognize your computer when you visit our web Platform (if you select the “remember me on this computer” option, and to personalize our web site for you. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookie by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector). Blocking cookies, however, can also have a negative impact on the usability of many web sites.

Cookies may have long-term expiration dates, or none, and thus can stay in your hard drive for months at a time. While you can remove them as instructed by the help content in your chosen browser, disabling cookies will prevent you from using our site. As with many transactional web sites, cookies must be enabled in order to use our site.

We use third-party tracking services (e.g. Omniture, Google Analytics, etc.) that use cookies to track non-personal information about visitors to our Platform in the aggregate (such as web page views and referral page information to track the success of our marketing efforts to bring people to our Platform as well as overall Platform performance). We use respective web beacons to gather information that lets us tune and improve our users’ browsing experience, as well as track user responsiveness to various advertising campaigns and user activities. As with cookies, the information these beacons collect is aggregated, anonymous “click stream” and transactional data, and is not associated with any users as individuals. No personal or sensitive information is transmitted to advertising partners (but some partners may use incoming IP addresses to avoid double-counting the number of new members who joined as a result of the advertising campaign).

If you would like more information about the use of third-party cookies and tags, or the process of opting out of such cookies or tags, please visit http://www.google.com/privacy.html.

Compliance with State and Federal Laws

This privacy policy may not constitute your entire set of privacy rights, as these may also vary from state to state. To be certain of your privacy rights, you may wish to contact the appropriate agency in your state that is charged with overseeing privacy rights of consumers. Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain your personal information for at least seven years in order to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.

Links to Other Sites

We may offer links to partners’ sites. We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled or to facilitate our customers’ more effective use of our platform, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this privacy policy and may have different privacy policies or approaches to the handling of information. Further, we have no control over the content of these sites. Please consult the privacy policies on these sites before you provide them with any of your personal information.

Semble Security Policy

Industry-leading standards and controls

Semble takes strong steps to safeguard your personal and sensitive information through vigorous physical, electronic and operational policies and practices. All data is considered highly confidential. Data can only be read or written through defined service access points, the use of which is password-protected. The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the Internet) and servers with hardened operating systems. Access to the system, both physical and electronic, is controlled and sanctioned by a high-ranking manager.

Further, we also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that you when you connect to our web Platform you are actually on our Platform. SSL also ensures that all data entered into the web Platform is encrypted. To verify that SSL is being used, look for the key or padlock icon on your browser. The test involves viewing a distorted image of a word that a computer would not be able to interpret and then entering in the text shown in the image. Finally, we subject our systems to periodic security audits to ensure that your information is thoroughly protected and secure.

Secure, off-site hosting

We store all sensitive financial data such as Social Security numbers and bank accounts in a highly secure, separate environment from our web Platform.

Protection of account numbers

When we contact you about your account to confirm a funds transfer, we only reference the last four digits of your bank account number; this is done for your protection so that you will recognize the source or destination account as one which you own. Further, we employ strict access standards ensuring that only the senior-most employees or partner representatives have access to your account numbers and other sensitive information. This access is only granted in order to complete transactions which you request or to provide regular ongoing service to your account.

Passwords

At a minimum, we require the use of a minimum number of characters in your password. We have also instituted secure steps by which you can regain access to your account should you forget your password. Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password as a means of identifying yourself. You should never share your password with anyone, and if you ever receive an email purporting to come from Semble that asks for your password, you should immediately report this development.

What you can do

In addition to our own substantial efforts, you can take several precautions to protect the security of your computer and personal information. For instance, you can start by using a well-chosen password. You should avoid using any information that others can easily learn about you, such as a family member’s name or birthday, and you can also use special characters in place of letters. We also recommend that you change your password frequently. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on our Platform, be sure that you log out and close the browser window.

To protect your account, we send automatic notifications confirming certain actions taken on your account, such as changes to a password or external linked account. We do this for your own protection so that you can be sure no one else is making changes to your account without your knowledge. However, the security offered through these notifications can be undermined if other people have access to your email account. Therefore, you might consider restricting access to the email account you registered with on this Platform and/or changing your password on that email account frequently.

If you use a computer that is accessed by other people, such as in a public library or Internet cafe, we recommend that you take special precautions to protect the security of your account and personal data. When you are finished using our Platform, you should log out completely, then close the browser window and clear the browser’s cache files.

You should also be aware of fraudulent attempts to gain access to your account information known as “phishing.” Phishing is a tactic used by scammers in which unsuspecting people are brought to a web Platform by a genuine-looking email purporting to be from a legitimate company. The phony or “spoof” email takes the person to a web Platform that looks legitimate but in fact is not. Either in the email itself or on this fake site, scammers will ask for login information to gain access to people’s accounts and withdraw their money. We will never ask you for your login information in the context of any email. In general, you can protect yourself against phishing by never providing personal or login information via an email—instead, go the web Platform directly. You might also make it a habit to check the URL of a web site to be sure that it begins with the correct domain. In the case of Semble, you should always ensure the URL begins with https://semble.techhubwithashutosh.com or https://semble.techhubwithashutosh.com.

We May Make Changes to This Policy

As technologies, laws and user needs change, our Platform and its features will also change. This policy may be updated from time to time as such needs dictate, and we will always communicate these changes to you by posting them on this web Platform and/or by notifying you via email in the event of any substantive or material changes.

You may contact us at:

Semble
Attn: Semble
14205 SE 36th St Suite 100
Bellevue, WA  98004

Via email at: support@semble.techhubwithashutosh.com

If Semble is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our web Platform of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.